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Annection Website Terms of Use



Ann Capital LLP (referred to as “Annection”) appreciates your interest in us and your visit to our website (the “Site”) owned and operated by Annection. These Terms of Use (“Terms”) set forth the basic terms and conditions that govern your visit to and use of the Site. By using the Site, you agree to be bound by these Terms and all disclaimers and terms and conditions that appear on the Site now or in the future. These Terms may be updated by us at any time. Your continued use of the Site after any such modifications constitutes your acceptance of the modified terms and conditions. If you do not agree to receive these legal notices and to abide by these Terms for any reason you agree that your sole and exclusive remedy is to discontinue using the Site. Nothing contained in these Terms is intended to modify or amend any other written agreement you may have with us (“Other Agreements”), if any, which may currently be in effect. In the event of any inconsistency between these Terms and any Other Agreements, the Other Agreements will govern. Your compliance with these terms and all Other Agreements is a condition to your right to access the Site. Your breach of any provision of these Terms or Other Agreements will automatically, without the requirement of notice of other action, revoke and terminate your right to access the Site and you will be fully liable for conversion, misappropriation, trespass to chattels, and all other claims and causes, regardless of the identity of the claimant or injured party, arising from or relating to your continued use of the Site after such breach. Privacy For information on how Annection collects, uses, and discloses information from its users of the Site, please review our Website Privacy Policy. Your use of the Site indicates your consent to the data practices stated in our Website Privacy Policy. No Offer or Advice: You acknowledge that the content of the Site is for general, informational purposes only and is not intended to constitute an offer to sell or buy any securities or other assets or promise to undertake or solicit business, and may not be relied upon in connection with any offer or sale of securities or other assets. An offer or solicitation will be made only through a final private placement memorandum, subscription agreement and other related documents with respect to a particular investment opportunity and will be subject to the terms and conditions contained in such documents, including the qualifications necessary to become an investor. Annection makes no representations that any information provided via the Site is accurate, current, or complete. You are solely responsible for evaluating the risks and merits regarding the use of the Site and any services provided herein. We are not utilizing the Site to provide investment or other advice, and nothing on the Site is to be deemed a recommendation that you buy, sell or hold any security or other investment or that you pursue any investment style or strategy. If you would like investment, accounting, tax or legal advice, you should consult with your own advisors with respect to your individual circumstances and needs. Past Performance: Any performance data or comments expressed on the Site are an indication of past performance. Past performance is not indicative of future results; no representation is being made that any investment will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided. Forward­Looking Statements: The contents of the Site may contain forward­looking statements that are based on management’s beliefs, assumptions, current expectations, estimates, and projections about the financial industry, the economy, Annection itself or its investments. These statements are not guarantees of future performance and involve certain risks, uncertainties and assumptions that are difficult to predict with regard to timing, extent, likelihood and degree of occurrence. Therefore, actual results and outcomes may materially differ from what may be expressed or forecasted in such forward­looking statements. Furthermore, Annection undertakes no obligation to update, amend or clarify forward­looking statements, whether as a result of new information, future events or otherwise.



Site Contents

All content included on the Site, such as text, images, graphics, logos, articles and other materials, is the property of Annection or others and is protected by United Kingdom and international copyright and other laws. All trademarks and logos displayed on the Site are the property of their respective owners, who may or may not be affiliated with Annection. Nothing contained on the Site should be construed as granting, by implication, estoppel or otherwise, any license or right to use any content or trademark displayed on the Site without the written permission of Annection or such other third party that may own the content or trademark displayed on the Site. Nothing in these Terms shall constitute a waiver of any trademark or other intellectual property rights concerning name, logo or trademark. Please be advised that Annection may enforce its intellectual property rights to the fullest extent by law. Restrictions on Use The information, materials and other content of the Site may not be copied, displayed, distributed, licensed, modified, published, reposted, reproduced, reused, sold, transmitted, used to create a derivative work or otherwise used for public or commercial purposes without the express written consent of Annection. Our prior permission is required for (i) any commercial use of materials on this site; (ii) making more than minimal copies of site materials; and (iii) copying large portions of our site, such as by bots, robots or spiders that “harvest” the site. If you seek permission for such use of our site, please contact us at info@Annection.com. Any unauthorized use of the images may violate copyright laws, trademark laws, the laws of privacy and publicity and communications regulations and statutes. You warrant that when using the Site you shall not violate or facilitate any violation of any applicable local, state, federal or international law, statute, regulation, code or ordinance, including, without limitation, regulations promulgated by or the rules of any national or other securities exchange. The permission to use the Site granted by this terms of use automatically terminates if you breach any of the terms and conditions contained herein. 2 Notification to Annection If you believe that anything posted on the Site infringes any intellectual property right that you own or control, please provide Annection with the following written information: 1. Name, address, telephone number, e­mail address and physical or electronic signature of the rights holder, or someone authorized to act on the rights holder’s behalf; 2. A description of the intellectual property that you claim has been infringed upon; 3. A description of where the material that you claim is infringing is located on the Site, with enough detail that Annection may find it; 4. A written statement that you have a good faith belief that the disputed use is not authorized by the rights holder, its agent or the law; and 5. A statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the rights holder or authorized to act on the rights holder’s behalf. Annection’s agent for notice of claims of intellectual property right infringement on the Site can be reached by e­mail at info@Annection.com. Select Portfolio Investments Articles accessible through the site (the “Articles”) may contain descriptions and analysis for select Annection adviser’s (collectively, “Annection” or “Annection Advisers”) portfolio investments, and do not contain analysis for all Annection portfolio investments. No assumptions should be made that these investments were or will be profitable. Not all Annection portfolio investments had or have the characteristics, prospects, performance or projected successes highlighted in the Articles. Past performance should not be relied upon as an indication of future results. For a full list of all Annection portfolio investments managed by such select Annection Advisers shown on this website, please click here. Source of Information: Certain information contained in the Articles was obtained from published and non­published sources, including from companies in which funds we advise have invested. Such information may not have been, and in many cases, has not been, independently verified by Annection and Annection not assume responsibility for the accuracy of such information (or for updating the Articles based on facts learned following its publication). The analyses contained in the Articles represent the respective author’s opinion on the date of the Article’s publication and these assessments were not independently verified. Modifications to Content: We may, at our discretion, modify or discontinue any of the content of this site, or any portion thereof, with or without notice.



Links from Other Websites

The Site may contain links to, or may be linked from, other sites that are not maintained by us and to which we have not provided permission. We not endorse, have any responsibility for, or make any representations about, any other sites, including their products and services, content, communications and website use policies. Annection has neither reviewed the contents of these third­party websites nor does Annection claim any responsibility for the content or suitability of these third­party websites and Annection makes no express or implied warranty about the accuracy, copyright compliance, legality, merchantability or any other aspect of the content of such links. The use of third party websites is entirely at your own risk. We expressly disclaim any responsibility for your access to or use of such other sites. By accessing these links, you acknowledge that such other sites or locations are not under the control of Annection and you agree that Annection shall not be responsible for any information or additional links found at such site or location, or for your use of such information.



Confidentiality

All information available through the restricted area of the Site is confidential and proprietary to us. This includes all investment information and results, offering materials, financial statements and other information provided through this part of the Site. You will use your best efforts to keep all this information strictly confidential. You will not disclose any of this information to any person or use it for any purpose other than as strictly permitted by us, in writing.



Login I.D. and Passwords

Access to specific areas of the Site may require the use of a Login I.D. and associated password. If you have a Login I.D. and password, you are responsible for the activities which occur in connection with their use and are to take steps to protect them from misuse. If you become aware of any unauthorized use of, loss or theft of your Login I.D. or password, immediatelyinform Annection at info@Annection.com . Annection will not be responsible or liable, directly or indirectly, in any way for any loss or damage of any kind incurred as a result of, or in connection with, your failure to comply with this section of the Terms.



Disclaimer

SITE, ALL INFORMATION AND MATERIALS AVAILABLE ON OR THROUGH THE SITE AND ALL SERVICES OFFERED IN CONNECTION WITH THE SITE ARE PROVIDED AS IS; AS AVAILABLE AND WITH ALL FAULTS. TO THE FULLEST EXTENT PERMITTED BY LAW, Annection DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON­INFRINGEMENT.



Limitation of Liability

BY USING THE SITE, YOU ACKNOWLEDGE: (1) THAT YOUR USE OF THE SITE IS AT YOUR SOLE RISK; (2) THAT YOU ASSUME FULL RESPONSIBILITY FOR ALL COSTS ASSOCIATED WITH YOUR USE OF THE SITE; AND (3) THAT ANNECTION SHALL NOT BE LIABLE FOR ANY DAMAGES, LOSSES OR LIABILITIES OF ANY KIND RELATED TO YOUR USE OF OR INABILITY TO USE THE SITE, INCLUDING WITHOUT LIMITATION, DIRECT, INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE, COMPENSATORY OR CONSEQUENTIAL DAMAGES, LOST PROFITS AND/OR LOSS OF OR DAMAGE TO PROPERTY WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE STRICT LIABILITY, OR ANY OTHER BASIS, EVEN IF Annection HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IN NO EVENT SHALL Annection BE LIABLE FOR ANY DAMAGES, LOSSES OR LIABILITIES, IN CONNECTION WITH YOUR RELIANCE ON OR USE OR INABILITY TO USE THE INFORMATION, MATERIALS, PRODUCTS OR SERVICES ON THE SITE, OR IN CONNECTION WITH ANY FAILURE OF PERFORMANCE, ERROR, OMMISSION, INTERRUPTION, DEFECT OR DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS, LINE OR SYSTEM FAILURE OR OTHER COMPUTER MALFUNCION EVEN IF ANNECTION IS ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, LOSSES, OR EXPENSES. NEITHER ANNECTION NOR ANY PARTY INVOLVED IN CREATING, PRODUCING OR DELIVERING THE SITE SHALL BE LIABLE FOR ANY DAMAGES, INCLUDING WITHOUT LIMITATION, DIRECT, INCIDENTAL, CONSEQUENTIAL, INDIRECT OR PUNITIVE DAMAGES ARISING OUT OF ACCESS TO, USE OF OR INABILITY TO USE THE SITE, OR ANY ERRORS OR OMISSION IN THE CONTENT THEREOF. THIS LIMITATION INCLUDES DAMAGES TO, OR FOR ANY VIRUSES THAT INFECT YOUR COMPUTER EQUIPMENT. 4 Annection RESERVES THE RIGHT TO ALTER OR REMOVE THE CONTENT OF THE SITE OR SUSPEND OR TERMINATE YOUR USE IN ANY WAY, AT ANY TIME, FOR ANY REASON, WITHOUT PRIOR NOTIFICATION, AND WILL NOT BE LIABLE IN ANY WAY FOR POSSIBLE CONSEQUENCES OF SUCH CHANGES.



Governing Law

You agree that your use of this site and any disputes relating to any of them shall be governed in all respects by the laws of England and Wales, without giving effect to its conflict of laws principles. The failure of Annection to act with respect to a breach of these Terms by you or others does not constitute a waiver and will not limit Annection’s rights with respect to such breach or any subsequent breaches. Class Action Waiver: You agree that if any dispute should arise between you and Annection, you will bring your claim on an individual basis and waive your right to pursue any claim in a class action. Dispute Resolution: You and Annection mutually agree that any dispute of any kind arising out of the Terms, our Website Privacy Policy, or your use of the Site will be resolved through the courts of England and Wales. Any claim must be brought on an individual basis and seek no class relief. This section shall also be construed as a written agreement to resolve a dispute of any kind between you and Annection that may arise through the use of the Site. The hearing shall be conducted in the county of your residence. For any claim in which you seek US $10,000.00 or less, you shall have the choice as to whether the hearing is conducted in person, by telephone, or instead the judge decides the dispute without a hearing. Severability If any provision of these Terms is found to be invalid, void, or for any reason unenforceable, it will be construed in such a manner that would make the provision valid or enforceable. If it is not possible to construe the provision in such a manner that would make it valid or enforceable, then only the term or portion of the provision that renders it unenforceable will be stricken without affecting the enforceability of the remaining provisions. Complete Agreement: These Terms and our Website Privacy Policy constitute the entire agreement between you and Annection relating to the public facing elements of the Site and your use of these portions of the Site, and supersede any prior agreements or understandings not incorporated herein with regards to these portions. Certain restricted areas of the Site may require you to agree to supplemental terms and conditions. These Terms are not intended to modify or amend Other Agreements you may have with Annection regarding other matters. 5 International Use: The Site is operated and controlled by us in the United Kingdom. Due to the global nature of the Internet, the Site may be accessed by users in countries other than the United Kingdom. We make no warranties that materials on this site are appropriate or available for use in such locations. If it is illegal or prohibited in your country of origin to access or use this site, then you

should not do so. Those who choose to access this site outside the United Kingdom do so on their own initiative and are responsible for compliance with all local laws and regulations. You agree to comply with all local laws, rules and regulations including, without limitation, all laws, rules and regulations in effect in the country in which you reside and the country from which you access the Site. The information on this Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject Annection or its affiliates to any registration requirement within such jurisdiction or country. Any offer for any matter made on this Site is void where prohibited.



Termination

Notwithstanding anything in these Terms or on the Site, Annection reserves the right, without notice and in its sole discretion, to terminate your license to use the Site, and to block or prevent your future access to and use of the Site or any other site operated by Annection. Contact Information: Thank you for visiting our Site. Please contact us at info@annection.com if you have any questions about our Site or these Terms. Electronic mail or other communications through this Site to Annection (or any of its employees, agents or representatives) may not be secure and we do not guarantee the confidentiality of such communications.


PRIVACY


Annection Privacy Policy

Introduction

Welcome to the Ann Capital LLP's privacy policy.

Ann Capital LLP, trading as Annection, provides financial advisory services to cross-border transactions and investments (“our business”). Annection respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Purpose of this privacy policy

This privacy policy aims to give you information on how Annection collects and processes your personal data through your use of this website, including any data you may provide through this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Annection is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy policy).

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

1.               The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

·       Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

·       Contact Data includes address, email address and telephone numbers.

·       Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].

·       Financial Information including account and transactional information and history Risk Data / Ratings.

·       Economic Crime related information (e.g. Financial Crime and Fraud Information).

·       Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2.               How is your personal data collected?

We use different methods to collect data from and about you including through:

·       Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you give us feedback or contact us.

·       Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

·       Third parties or publicly available sources. We will receive personal data about you from various third parties.

3.               How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

·       Where we need to perform the contract we are about to enter into or have entered into with you.

·       Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

·       Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Lawful basis for   processing including basis of legitimate interest

To manage client   relationships; engage stakeholders

In order to   provide and ensure we offer the best service to you and relevant parties,   information can be used to manage relationships for the benefit of you and   relevant parties.

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover   debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy   policy

(b) Asking you to leave a review or take a survey

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our   records updated and to study how customers use our products/services)

To administer and protect our business and this website   (including troubleshooting, data analysis, testing, system maintenance,   support, reporting and hosting of data)  

(a) Necessary for our legitimate interests (for running   our business, provision of administration and IT services, network security,   to prevent fraud and in the context of a business reorganisation or group   restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to   you and measure or understand the effectiveness of the advertising we serve   to you

Necessary for our legitimate interests (to study how   customers use our products/services, to develop them, to grow our business and   to inform our marketing strategy)

To use data analytics to improve our website,   products/services, marketing, customer relationships and experiences

Necessary for our legitimate interests (to define types of   customers for our products and services, to keep our website updated and   relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services   that may be of interest to you

Necessary for our legitimate interests (to develop our   products/services and grow our business)

To prevent and detect crime related to economic crime   including fraud and financial crime

This is within the public interest to carry this   processing out

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.               Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

·       Internal Third Parties

·       External Third Parties

·       Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.               Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6.               Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.